IRS Dispute definition

IRS Dispute means any and all litigation arising from or relating to the IRS Claims or the IRS Adversary Proceeding.
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IRS Dispute means the adversary proceeding (including appeals, if any) initiated by AFGI as debtor in the Chapter 11 Case against the IRS (captioned Ambac Financial Group, Inc. vs. United States of America, Case No. 10-04210).
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IRS Dispute means a dispute between a Relevant Person and the Internal Revenue Service or other governmental entity arising out of a determination by the Internal Revenue Service or other governmental entity that FIRPTA tax is due and payable in connection with a matter referred to in clauses (a), (b), (d) or (e) of the definition of Conversion Triggering Event in this Section (C)(4.1) of this Article IV.
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Examples of IRS Dispute in a sentence

  • The Debtor shall not settle or offer to settle the IRS Dispute, incur any defense costs or otherwise assume any contractual obligation, admit any liability, voluntarily make any payment or otherwise agree to any judgment with respect to the IRS Dispute without the written consent of each of AAC, which shall not be unreasonably withheld, and the Rehabilitator, in its sole and absolute discretion.

  • Each of AAC and the Rehabilitator hereby consents to the defense costs incurred by the Debtor and AAC (i) prior to the Plan Settlement Signing Date with respect to the IRS Dispute, the invoices for which have been provided to AAC and the Rehabilitator, and (ii) in implementing the litigation strategy that the Debtor is currently pursuing in connection with the IRS Dispute.

  • Additionally, confirmation of the Plan and entry of the Confirmation Order shall be without prejudice to the IRS in the IRS Dispute or elsewhere.

  • Certain NOLs generated by the Ambac Consolidated Group on or prior to, and existing on, September 30, 2011 (the “ Determination Date”), not taking into account the consequences of any settlement with respect to the IRS Dispute (“Pre-Determination Date NOLs”), shall be available for use by the AAC Subgroup as set forth in the Amended TSA and as described below.

  • Within fifty-five (55) days after the end of each quarter during the term of this Agreement, each of AFGI and Ambac shall calculate each Affiliate’s expense allocation for each service department or function (including fees and expenses relating to the IRS Dispute pursuant to Section 4 of the Mediation Agreement), and prepare reports which provide the individual and aggregate expense allocation to each Affiliate (including AFGI and Ambac) for all service departments and functions for such quarter.

  • A reduction in the Pre-Determination Date NOLs as a result of a resolution of the IRS Dispute shall be allocated between the Allocated NOLs and the AFG Allocated NOLs (as defined below) in a manner to be agreed upon by the parties.

  • Although progress has been made towards a resolution of the IRS Dispute, a final, binding settlement has not been reached.

  • The Amended TSA shall address certain issues including, but not limited to, the following: (a) Any NOLs generated by the Ambac Consolidated Group on or prior to, and existing on, September 30, 2011 (the “Determination Date”), not taking into account the consequences of any settlement with respect to the IRS Dispute (“Pre-Determination Date NOLs”), shall be available for use by the AAC Subgroup as set forth in the Amended TSA.

  • Such mediation has not yet resulted in a consensual resolution of the IRS Dispute, however, further meetings may occur in the near term.

  • Their success was short lived, however, for the Jebusites regained Jerusalem soon afterwards, whilst Gaza, Askelon and Ekron were captured by the Philistines several years later.Many tribes were now distanced from the central sanctuary and there was, no doubt, the temptation to accommodate elements of Cana- anite Baalism within their faith.

Related to IRS Dispute

  • Formal Dispute means a written objection by an Interested Party to any of the following:

  • Arbitrable Dispute means any dispute arising under or in connection with this Agreement.

  • Tax Dispute has the meaning set forth in Section 5.06.

  • Xxxx Dispute Notice means the notice issued by a Party raising a Dispute regarding a Monthly Xxxx or a Supplementary Xxxx issued by the other Party;

  • Agreement Disputes shall have the meaning set forth in Section 6.1.

  • Legal Dispute means any action, suit or proceeding between or among the Parties arising in connection with any disagreement, dispute, controversy or claim arising out of or relating to this Agreement or any related document.

  • Relevant Dispute means any difference between the parties arising out of or in connection with this contract; "Relevant Force Majeure Event" has the meaning ascribed to it in Clause 17.1;

  • Resolved With respect to a Repurchase Request, means that (i) the related Material Defect has been cured, (ii) the related Mortgage Loan has been repurchased in accordance with the related Mortgage Loan Purchase Agreement, (iii) a mortgage loan has been substituted for the related Mortgage Loan in accordance with the related Mortgage Loan Purchase Agreement, (iv) the applicable Mortgage Loan Seller has made a Loss of Value Payment, (v) a contractually binding agreement has been entered into between the Enforcing Servicer, on behalf of the Trust, and the related Mortgage Loan Seller that settles the related Mortgage Loan Seller’s obligations under the related Mortgage Loan Purchase Agreement, or (vi) the related Mortgage Loan is no longer property of the Trust as a result of a sale or other disposition in accordance with this Agreement.

  • Billing Dispute means the dispute of an invoice prepared by an Operator to the Other Operator which is made in good faith.

  • Dispute means any dispute, controversy, claim or difference of whatever nature arising out of, relating to, or having any connection with this Agreement, including a dispute regarding the existence, formation, validity, interpretation, performance or termination of this Agreement or the consequences of its nullity and also including any dispute relating to any non-contractual rights or obligations arising out of, relating to, or having any connection with this Agreement.

  • Technical Dispute has the meaning specified in Section 12.2;

  • Reconciliation Dispute has the meaning set forth in Section 7.9 of this Agreement.

  • Expedited Dispute Timetable means the accelerated timetable for the resolution of disputes as set out in paragraph 2.6;

  • Dispute Resolution Procedure means the procedure for resolution of Disputes set forth in Article 26;

  • Dispute Board (DB) means the person or persons named as such in the SCC appointed by agreement between the Procuring Entity and the Contractor to make a decision with respect to any dispute or difference between the Procuring Entity and the Contractor referred to him or her by the Parties pursuant to GCC Sub-Clause 46.1 (Dispute Board) hereof.

  • Labor dispute as used here, means a strike, lockout, or other labor dispute between the Employer and its Employees, during which time the Employee is not paid by the Employer.

  • Dispute Period shall have the meaning specified in Section 9.3(a).

  • non-disputing Party means the Party to this Treaty which is not a party to a dispute under Chapter IV of this Treaty.

  • Billing Dispute Notice means a formal, written notice submitted to MultiChoice by the Customer in terms of this Procedure.

  • trade dispute means any dispute or difference between employers and workmen, or between workmen and workmen, connected with the employment or non-employment, or the terms of employment, or with the conditions of labour, of any person;

  • Dispute Resolution Process means the process described in clause 9

  • Dispute Resolution Scheme means the Electricity and Gas Complaints Commission or such other dispute resolution scheme approved or provided for in accordance with section 95 of the Act;

  • Notice of Dispute has the meaning provided in Section 2.1(f)(iii) of this Commercial Shared-Loss Agreement.

  • Tax Controversy means any audit, examination, dispute, suit, action, litigation or other judicial or administrative proceeding by or against the IRS or any other Taxing Authority.

  • Dispute Resolution Procedures means the procedures outlined in Annexure A of the MSA Determination.

  • dispute resolution proceeding ’ means any process in which an alternative means of dispute resolution is used to resolve an issue in controversy in which a neutral is appointed and specified parties participate;